CFIUS Non-Notified Transaction Enforcement: Cooley’s Five-Year Lookback

Cooley – March 2025 marked the fifth anniversary of the Committee on Foreign Investment in the United States (CFIUS) initiative to “formalize and centralize” within the Department of the Treasury an enforcement function to identify and investigate “non-notified” transactions—i.e., cross-border acquisition and investment transactions that may have been subject to CFIUS jurisdiction but not formally “notified” to CFIUS for review.